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TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Section 115JB(5) permits application of other Income-tax Act provisions in minimum alternate tax computation unless expressly barred. Capital gains eligible for section 54G relief under normal provisions may consequently receive corresponding exclusion while computing book profit, without fresh verification where eligibility and quantum are already accepted. An appellate authority may entertain an omitted consequential MAT claim when it arises from existing facts and the prescribed return form provides no specific adjustment field; the restriction on claims not made in the return applies to the Assessing Officer, not the appellate authority. Filing a return under section 139(4) within a CBDT-extended period does not by itself defeat substantive section 54G relief or require separate condonation.
Section 115JB(5) permits application of other Income-tax Act provisions in minimum alternate tax computation unless expressly barred. Capital gains eligible for section 54G relief under normal provisions may consequently receive corresponding exclusion while computing book profit, without fresh verification where eligibility and quantum are already accepted. An appellate authority may entertain an omitted consequential MAT claim when it arises from existing facts and the prescribed return form provides no specific adjustment field; the restriction on claims not made in the return applies to the Assessing Officer, not the appellate authority. Filing a return under section 139(4) within a CBDT-extended period does not by itself defeat substantive section 54G relief or require separate condonation.
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